Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Enhanced penalty for misreporting under section 270A requires identification of a specific statutory category of misreporting and factual findings establishing its ingredients. Mere omission of salary, interest or rental income from a return, followed by detection during reassessment, does not by itself establish misrepresentation, suppression, failure to record receipts, or another prescribed form of misreporting. Under-reporting and under-reporting resulting from misreporting are distinct defaults with different penalty consequences. Where proceedings were initiated solely on the aggravated misreporting charge, an appellate authority cannot recast the levy as a penalty for ordinary under-reporting after the misreporting charge fails.
Enhanced penalty for misreporting under section 270A requires identification of a specific statutory category of misreporting and factual findings establishing its ingredients. Mere omission of salary, interest or rental income from a return, followed by detection during reassessment, does not by itself establish misrepresentation, suppression, failure to record receipts, or another prescribed form of misreporting. Under-reporting and under-reporting resulting from misreporting are distinct defaults with different penalty consequences. Where proceedings were initiated solely on the aggravated misreporting charge, an appellate authority cannot recast the levy as a penalty for ordinary under-reporting after the misreporting charge fails.
Note: It is a system-generated summary and is for quick reference only.